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you just become numb to it. 
Q. Is it fair to say that she was frequently in the room while 
you were being sexually abused by Jeffrey Epstein when you were 
14, 15, and 16? 
MS. MENNINGER: Objection. 
THE COURT: I'll sustain. Please rephrase. 
Q. Was Maxwell in the room just once while you were being 
sexually abused by Jeffrey Epstein? 
A. No. 
Q. Was it just twice? 
A. No. 
Q. Approximately how many times? 
A. I don't know, but more than twice. 
MS. MOE: Your Honor, just one moment, please. 
THE COURT: Sure. 
Q. I want to ask you about that third category that I asked 
you about the incidents where it was you and Maxwell and 
Epstein and other people who were in the room. 
What was typically happening before incidents like 
that would start? 
A. It would typically be something very casual, like hanging 
out by the pool or sitting around in a living room or in the 
kitchen and just be, like, very seemingly casual hangouts. 
Q. When you would spend time at Epstein's house in Palm Beach, 
were there other women present in the house? 
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A. Yes. 
Q. Would those women sometimes be involved in these 
encounters? 
A. Yes. 
MS. MOE: Just one moment, your Honor. 
THE COURT: Sure. 
Q. How would you typically transition from hanging around the 
house or hanging around the pool to the incidents that you've 
described? 
A. We were summoned to follow Jeffrey up into his bedroom or 
massage room. 
Q. Can I ask you to please look at the binder in front of you. 
If you could please turn to what's been marked for 
identification as Government Exhibit 245. Thank you. 
Do you recognize that? 
A. Yes. 
Q. What is Government Exhibit 245? 
A. It's two pictures of myself. 
MS. MOE: Your Honor, the government offers Government 
Exhibit 245 under seal. 
MS. MENNINGER: No objection, your Honor. 
THE COURT: Thank you. GX245 is admitted under seal 
consistent with my ruling, allowing this witness to testify 
using a pseudonym. 
(Government's Exhibit 245 received in evidence) 
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MS. MOE: Thank you, your Honor. May the jurors turn 
to Exhibit 245 in their binders? 
THE COURT: Yes, please. You may pick up your binder 
and turn to GX245. 
BY MS. MOE: 
Q. Looking at Government Exhibit 245, do you recognize those 
two photographs? 
A. Yes. 
Q. Can you please describe to the jury what those two 
photographs are? 
A. Well, the large 
larger photograph in the back is a 
modeling picture of me, approximately age 15. The one in the 
front is like my first head shot at about 19. 
Q. For the smaller picture in the corner, did you give a copy 
of that photograph to Jeffrey Epstein? 
A. I did. 
Q. Did you write a note on that photograph? 
A. I did. 
Q. What did you write on the photograph? 
A. Well, cringey enough, I wrote, thanks for rocking my world. 
Q. Why did you write that? 
A. Well, my mother made me send him a picture after I had 
gotten my first big job, and that's when I had taken this 
picture and, in fairness, I used to write really bad captions 
for people when I would write -- sign a headshot. So that was 
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my attempt at being cool, I guess. 
Q. I want to ask you, 
, how did you feel at the time about 
the attention that Epstein and Maxwell were paying to you when 
you were in middle school and high school? 
A. How did I feel about the attention? 
Q. Yes. 
A. Initially, I felt special. You know, I didn't -- I didn't 
really have much support or attention at home, so he was 
someone who was seemingly looking out for me and caring for me 
is how it felt. 
Q. Why was that important to you at the time, to feel cared 
about? 
A. Because I didn't have any family that made me feel cared 
about. 
Q. In your adult life, how has what happened to you with 
Maxwell and Epstein affected your relationships? 
MS. MENNINGER: Objection, your Honor. Relevance. 
THE COURT: Just a moment. 
MS. MENNINGER: May we have a sidebar if there is 
any --
THE COURT: Let's do that. 
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(In open court) 
THE COURT: You may proceed, Ms. Moe. 
MS. MOE: Thank you, your Honor. 
BY MS. MOE: 
Q. Let me back up and ask you a few questions. You testified 
in the beginning Epstein and Maxwell made you feel special. 
Can you explain to the jury what it is they did that made you 
feel special when it first started? 
A. Well, they made me feel special by spending time with me, 
talking to me, asking me about my family, my interests, what _ 
was doing, what I was doing in school, what I wanted to do with 
my life. They took me to the movies, they took me shopping, 
and took me on field trips, I guess you could say. 
Q. And to be clear, during this time, did Maxwell talk with 
you about your school and your family and what was going on 
with you and your life? 
A. Yeah. 
Q. You testified that you felt this way in the beginning. Did 
there come a time when that changed? 
A. Yes. 
Q. Can you tell the jury about that. 
A. Well, it changed when the abuse started happening. 
Q. Can you explain for the jury how has what Maxwell and 
Epstein did to you affected your relationships as an adult? 
A. That's a loaded question. Sure you could ask a lot of 
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people their opinions on that. How do you navigate a healthy 
relationship with a broken compass? I didn't even understand 
what real love is supposed to look like. It ruined my 
self-esteem, my selfworth, I don't know how men were supposed 
to treat me and how I was supposed to reciprocate any of that. 
It led me to not trust people and probably make bad decisions 
in future boyfriends. 
Q. Earlier, we were talking about the years that you lived in 
Palm Beach and about the time when you moved away from Palm 
Beach. Can you tell the jury, approximately when did you move 
away from Palm Beach? 
A. Approximately 17 years old. 
Q. Did you go to school when you moved to New York City? 
A. Yes. 
Q. Where did you go to school? 
A. Professional Children's School. 
Q. When you moved to New York City when you were 17 to go to 
the Professional Children's School, who paid for your tuition? 
A. Jeffrey Epstein. 
Q. About how old were you when you started school in New York 
City? 
A. I just turned 18. 
Q. What year of school were you starting? 
A. Senior year of high school. 
Q. During your senior year of high school, did you spend time 
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with Jeffrey Epstein? 
A. Yes. 
Q. Did you spend time with Ghislaine Maxwell that year? 
A. Yes. 
Q. During that year when you were a senior in high school, did 
you continue engaging in sexualized massages with Jeffrey 
Epstein? 
A. Yes. 
Q. To be clear, did you want to keep doing that? 
A. No. 
Q. Did you graduate from school that year? 
A. Yes. 
Q. Did there come a time after you graduated when you moved 
away from New York? 
A. Yes. 
Q. Approximately when was that? 
A. October of 1999. 
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Q. Where did you go when you moved away from New York City in 
October of '99? 
A. Los Angeles, California. 
Q. Why did you move to Los Angeles? 
A. Because I got a job 
Q. 
can you tell the jury what kind of work do you do 
now? 
A. I am grateful to still be 
Q. For how many years have you been employed as 
A. Twenty-two years. 
Q. After you moved to California, did you stay in touch with 
Epstein and Maxwell? 
A. Yes. 
Q. For about how many years? 
A. Until approximately the end of 2002. 
Q. Approximately how old were you during that year? 
A. Twenty-two. 
Q. During the year that you were -- withdrawn. 
After you moved away, did you continue to travel with 
Maxwell and Epstein? 
A. With Epstein for sure. 
Q. When you traveled with Epstein in your early twenties, did 
you travel in his private jet? 
A. Yes. 
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Q. Did there come a time when you stopped being in touch with 
Jeffrey Epstein? 
A. Yes. 
Q. Approximately when was that? 
A. The end of 2002. 
Q. And why did you stop seeing him at the end of 2002? 
A. Because I fell madly in love with someone, and we got very 
quickly engaged. And Jeffrey would call me. And my new fiancé 
would ask, Who is this person who calls you and that you sort 
of have to drop everything for to take that call? 
And I said, Oh, it's -- that's my godfather. 
And he just kind of said, Well, what do you mean your 
godfather? You just tell him you'll call him back. 
I said, No, it doesn't work that way. 
And he had a pretty abrasive personality himself, this 
guy. And he said, Well, don't call him back. 
And that was sort of -- well, that wasn't the end of 
it. I didn't call him back. And then he tried contacting me 
again and leaving me voicemails that became increasingly 
agitated in saying that I need to call him back, he was coming 
into town to visit, and he wanted to see me, and that I need to 
be grateful and remember what he's done for me. Because my 
mother had still been living in an apartment in New York after 
I moved away that he was paying for. And then I didn't return 
his call. 
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And do you want me to continue? 
Q. That's all right. 
Was that the last contact you had with him? 
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A. Yes. 
Q. I think you mentioned that the person you were dating at 
that time you were engaged to. Did you end up marrying him? 
A. No. 
Q. Did there come a time in the late 2000s when you were in a 
romantic relationship with someone else? 
A. In the late 2000s? Yes. 
Q. Approximately what years were you dating that man? 
A. 2007 through 2013. 
Q. For today's purposes, I'm going to refer to that man as 
Will you do that? 
A. Yes. 
Q. While you were together, did you ever tell 
that you'd 
been sexually abused by Maxwell and Epstein? 
A. Yes. 
Q. Why did you tell him? 
A. I told him because that was around the time that you 
started seeing on the news that Epstein had been arrested and, 
you know, you sort of would see his face everywhere and it 
would make me very emotional. And my boyfriend at the time 
would notice that and kind of wonder. And you know -- and then 
there would be moments of vulnerability that I sort of started 
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to share, like, some of the things that had happened to me, not 
in detail, but, you know, it took a long time to really share 
any of that stuff with him. 
Q. Directing your attention to September of 2019, were you 
interviewed by the FBI that month? 
A. Yes. 
Q. Before that time, had you ever spoken with law enforcement 
about Jeffrey Epstein or Ghislaine Maxwell? 
A. What was the month you mentioned? 
Q. Before you were interviewed by the FBI in September of 
2019, had you ever spoken with law enforcement about what had 
happened to you with Maxwell and Epstein? 
A. I think that month is incorrect. I think it's --
Q. Approximately what month do you remember being interviewed 
by the FBI? 
A. May. 
Q. Of what year? 
A. Of 2019. 
Q. Before that first interview, had you ever spoken with law 
enforcement about what happened to you with Maxwell and 
Epstein? 
A. No. 
Q. Did there come a time when you sued Ghislaine Maxwell? 
A. Yes. 
Q. Approximately when did you file that lawsuit? 
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Q. To be clear, was that after you had told the government 
what had happened to you? 
A. Yes. 
Q. At the time that you sued Ghislaine Maxwell, did you also 
sue the Estate of Jeffrey Epstein at that same time? 
A. Yes. 
Q. Did you bring that lawsuit under a pseudonym to protect 
your identity? 
A. Yes. 
Q. After you filed that lawsuit, did you participate in a 
victim compensation fund for victims of Jeffrey Epstein? 
A. Yes. 
Q. What did you do as part of submitting a claim to that fund? 
A. Well, I had to submit documents and speak to the people who 
ran the fund. 
Q. Did the fund award you money? 
A. Yes. 
Q. How much money did the fund award you? 
A. $5 million. 
Q. Did that money come from the Estate of Jeffrey Epstein? 
A. Yes. 
Q. Did you receive all of that money? 
A. No. 
Q. And why not? 
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A. Because some of it has to go to counsel and litigation and 
filing documents and such. 
Q. How much did you ultimately receive? 
A. Approximately 2.9 million. 
Q. Has that money been wired to you already? 
A. Yes. 
Q. As part of the settlement that you received from the fund, 
were you required to dismiss your lawsuit against Maxwell and 
the Estate of Jeffrey Epstein? 
A. Yes. 
Q. And did you dismiss the lawsuit against Maxwell after you 
received an award from the fund? 
A. Yes. 
Q. Based on your understanding, will the jury's verdict in 
this case affect the award that you received from the victim 
compensation fund? 
MS. MENNINGER: Objection, your Honor. 
THE COURT: Just a moment. 
I have to hear you. 
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(At sidebar) 
THE COURT: The question is whether the jury's verdict 
will affect what she receives from the victim compensation 
fund? 
MS. MENNINGER: Right. I think she has a lack of 
personal knowledge about that, your Honor. It's a legal 
conclusion, a legal question. She's not the right witness to 
talk about that. 
THE COURT: You want the jury -- you want to put in 
front of the jury that the involvement in this case affects 
payout from the legal compensation fund. 
MS. MENNINGER: Well, your Honor, this is something 
that we litigated, which is, any suggestion that the victim's 
compensation fund was based on some kind of finding of validity 
of her claims. 
THE COURT: I agree with that. I don't see what that 
has to do with this question. 
MS. MENNINGER: I think she has told this story to the 
victim compensation fund, they have given her money, and now if 
she is found -- if our client was found not guilty, for 
example, I don't know what the ramifications would be for a 
fund who has determined --
THE COURT: Well, the question to be phrased is what 
her understanding is. I mean, you have well put in issue the 
question of whether this fund impacts her motivation to tell 
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the truth or not, which is precisely why I granted the Rule 17 
subpoena and, I suspect, in the opening raised this issue 
precisely. So whether it's true or not, the question is what 
is her understanding. So if the question is phrased that way, 
I will overrule the objection. 
MS. MOE: Yes, your Honor. In fact, that is exactly 
how I phrased that question for that reason. 
MS. MENNINGER: I still think it's a legal conclusion, 
your Honor, asking someone, you know, what is the effect of a 
contract or what is -- how can a contract be dissolved. It's 
just not within the ken of a person who is not --
THE COURT: I can give a limiting instruction that 
testimony is not being offered for -- as a legal instruction, 
but for the witness's understanding. 
MS. MENNINGER: Sure. That would be better --
THE COURT: Any objection? 
MS. MOE: No, your Honor. 
I think this is very commonplace, it happens all the 
time. For example, when cooperators testify about their 
understanding of whether, for example, a verdict in a case 
affects their cooperation agreement with the government, I 
don't think there's a limiting instruction; because, again, the 
question is about this person's understanding. I can make that 
very clear when I ask the question. It's directly responsive 
to defense arguments about whether this witness has a motive to 
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MS. MENNINGER: In cooperating situations, your Honor, 
the sentence happens after the testimony. 
THE COURT: Well, they are not the same, but I think 
the point is the same. 
I'll give a limiting instruction that -- after she 
testifies, that the jury should understand she's not providing 
legal instruction, but testifying as to her understanding in 
response to the question. And so with that -- and you'll say 
the question again, make sure it's phrased from her 
understanding. With that, I'll overrule. 
I don't see any reason this should be sealed. 
MS. MOE: No, your Honor. 
MS. MENNINGER: No, your Honor. 
MS. MOE: Just to avoid a second sidebar, I just 
wanted to flag, after asking this question, I expect the next 
question I would ask would be just simply, Do you have a 
financial stake in the outcome of this case? Again, that's 
about her understanding, whether she believes she has a 
financial -- which is exactly what the defense suggested in 
their opening. 
THE COURT: Oh, there's no doubt. 
MS. MOE: I just want to flag that. 
THE COURT: You have an objection to that question? 
MS. MENNINGER: No, your Honor. But I think she does 
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